The complaint, which has been posted online here, charges that Davis “converted political contributions to her personal use in violation of Election Code Section 253.035,” related to travel to New York City on September 9 and 10, 2014. These travel expenses were paid for by Davis’ campaign, but there was only one campaign event in New York City on September 10, and the rest of the events on her schedule were related to promoting the book, including seven separate media interviews, for example MSNBC’s Rachel Maddow Show.

Texas Election Code 253.035 prohibits converting a political contribution to personal use, and subsection (d) defines “personal use” as “a use that primarily furthers individual or family purposes not connected with the performance of duties or activities as a candidate for or holder of a public office.” If Davis is ultimately found to be in violation, subsection (f) states that she would be “civilly liable to the state for an amount equal to the amount of the converted contribution plus reasonable court costs.” Presumably, this would mean Davis would have to pay whatever her campaign spent on airfare, hotel, meals, and other transportation expenses related to the New York City trip.

This complaint follows a letter that Hamilton sent on Monday to the TEC, requesting an advisory opinion on whether Davis’ book tour was violating the law. As Breitbart Texas reported earlier this week, that letter requested the TEC to issue a ruling on whether promotional advertising by Davis’ publisher constituted an in-kind contribution to the campaign, whether it was permissible for the publisher and the campaign to pay for travel for events that also benefited the other, and how Davis should report the royalties from the book on her personal financial statements.

Breitbart Texas reached out to the Davis campaign for comment, but did not receive a response by the time of this article’s publication.